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Extraction Summary

6
People
4
Organizations
2
Locations
2
Events
3
Relationships
3
Quotes

Document Information

Type: Legal correspondence / court filing
File Size: 581 KB
Summary

A letter dated December 13, 2021, from defense attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter informs the court of the defense's intention to question attorneys Jack Scarola, Brad Edwards, and Robert Glassman and argues that these questions do not violate attorney-client privilege. The document cites legal precedents regarding the burden of proof for privilege claims.

People (6)

Name Role Context
Jeffrey S. Pagliuca Attorney
Author of the letter, representing Ghislaine Maxwell, from the firm Haddon, Morgan and Foreman, P.C.
Alison J. Nathan Judge
Recipient of the letter, presiding Judge of the United States District Court, Southern District of New York.
Ghislaine Maxwell Defendant
Subject of the case (United States v. Ghislaine Maxwell); the defense anticipates asking questions of specific witnes...
Jack Scarola Attorney/Witness
Attorney whom Ms. Maxwell anticipates questioning.
Brad Edwards Attorney/Witness
Attorney whom Ms. Maxwell anticipates questioning.
Robert Glassman Attorney/Witness
Attorney whom Ms. Maxwell anticipates questioning.

Organizations (4)

Name Type Context
Haddon, Morgan and Foreman, P.C
Defense law firm representing Ghislaine Maxwell.
United States District Court, Southern District of New York
Court where the case is being heard.
United States Government
Prosecution (Plaintiff) in the case.
Second Circuit Court of Appeals
Referenced in legal citations (2d Cir.).

Timeline (2 events)

2021-12-14
Document filed with the court (Document 544).
Southern District of New York
Future (Anticipated)
Questioning of Attorneys Jack Scarola, Brad Edwards, and Robert Glassman by the defense.
Court

Locations (2)

Location Context
Address of Haddon, Morgan and Foreman, P.C.
Address of the United States District Court.

Relationships (3)

Jeffrey S. Pagliuca Attorney-Client Ghislaine Maxwell
Pagliuca is writing on behalf of Maxwell's defense.
Ghislaine Maxwell Legal Adversary / Witness Jack Scarola
Maxwell anticipates asking questions of Scarola.
Ghislaine Maxwell Legal Adversary / Witness Brad Edwards
Maxwell anticipates asking questions of Edwards.

Key Quotes (3)

"I write to alert the Court to the questions Ms. Maxwell anticipates asking Attorneys Jack Scarola, Brad Edwards, and Robert Glassman, and to explain why none of the answers they will offer are protected by the attorney client privilege."
Source
DOJ-OGR-00008364.jpg
Quote #1
"None of the questions Ms. Maxwell intends to ask these witnesses implicates the attorney-client privilege."
Source
DOJ-OGR-00008364.jpg
Quote #2
"Rather, all the questions concern interactions between the"
Source
DOJ-OGR-00008364.jpg
Quote #3

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